KEY QUESTIONS
Specific Goals: What were TVA’s original quantitative and qualitative goals for GPS? After seven years, what progress has been made toward the attainment of each of the original goals? What are TVA’s quantitative and qualitative goals for GPS today?
Vision: What does TVA envision for the future of GPS? Why isn’t GPS (or even renewable energy in general) mentioned in TVA’s new strategic plan? Since it's not in the strategic plan, is there any other kind of long-range plan or vision statement for GPS?
Supply: According to the KUB website, "TVA has indicated it would not make a decision on adding additional resources until existing Green Power generation is approaching full utilization." When does TVA foresee this happening? What "additional resources" does TVA intend to add? In other words, when should the public expect TVA to acquire truly significant green power productive capacity (or other sources of green energy)?
Demand: Why does TVA say or imply that GPS sales (voluntary contributions) are the true measure of “demand” for green energy? Isn’t this inconsistent with TVA's market research which reported that "84% of customers surveyed said they would like a green power product"? What are the pros and cons of GPS' becoming a "mandated program"?
Accounts: What kind of a “fund” does TVA use to account for all GPS income and GPS outgo (expenses)? Since this “fund” receives voluntary contributions from the public (in exchange for certain promises), TVA must be legally and morally obliged to publish periodic income and expense reports, balance sheets, etc. Where are these reports?
Accreditation: Why does TVA imply that CRS certifies the entire GPS program, when CRS (Green-e) concerns only production -- not expenses, sales, income and all other aspects of GPS? CRS web pages speak of the Green-e Process Audit, the Green-e Marketing Compliance Review, and "pricing and contract disclosure to customers in the standardized format, required by the Green-e Code of Conduct." Where are these reports?
Statistics: Why does the TVA website publish detailed daily statistics for each of the 16 solar sites (a very tiny part of GPS) but only very generalized and sometimes missing quarterly statistics for the vastly more important wind and methane generation projects?
Ethics: What has TVA learned from or about the TVA employee who wrote publicly in May 2007, "TVA needs to take a hard look from an ethical perspective in marketing this product [GPS]. It appears to be an Enron-type house build on sand with no apparent ac-countability to the customer."
Public Inquiry: Does TVA plan to respond to (or even acknowledge) the letter about GPS transparency which was read to the TVA Board on August 1, 2007, by Eugene Burr of Tennessee Valley Unitarian Universalist Church (which buys 25 blocks/month)? (A copy is attached.)
DETAILED QUESTIONS
(1) GPS Goals and Vision
(2) GPS Accounts and Audits
(3) GPS Production (and Cost of Production)
(4) Buffalo Mountain
(5) GPS Distribution and "Imports"
(6) GPS Sales (and Income from Sales)
(7) GPS Marketing Advertising
(8) TVA Strategic Plan
(9) Other TVA Polities
(1) GPS Goals and Vision
What were TVA’s original quantitative and qualitative goals for GPS? FYI, a TVA presentation in August 2001 said: "Provide customer choice, Positive public relations, Reinforce environmental stewardship role, and Supplement TVA renewable energy strategy." The KUB website says: "You can help advance the technology [R&D] and increase the amount of electricity generated from cleaner sources." What about a target to cut carbon dioxide emissions?
After seven years, what progress has been made toward the attainment of each of the original goals? What has TVA learned or achieved from GPS? What benefits has the public obtained? What adjustments have been made to the original goals? How much of TVA’s own money (internally generated funds and/or power program financings) has been spent on green energy (GPS)?
What are TVA’s quantitative and qualitative goals for GPS today? What promises (real or implied) does TVA make to subscribers who voluntarily pay a surcharge for GPS?
What does TVA envision for the future of GPS? Why isn’t GPS (or even renewable energy in general) mentioned in TVA’s new strategic plan? Since it's not in the strategic plan, is there any other kind of long-range plan or vision statement for GPS? Since GPS is such an infinitesimal part of total TVA generation (about 0.05%), what chance does GPS have of ever influencing TVA’s long-range plans and investment decisions?
According to the KUB website, "TVA has indicated it would not make a decision on adding additional resources until existing Green Power generation is approaching full utilization." When does TVA forecast new investment will occur, and what "resources" does TVA intend to add? In other words, when should the public expect TVA to increase green power productive capacity (or other sources of green energy)? This is, after all, the public’s expectation for GPS.
What is the role and current membership of the GPS steering committee? Where are its charter, by-laws, proceedings, etc.? Are its decisions and documents published, and, if not, why not? What responsibility do the committee's non-industry members have to represent the interests of the public? How often does steering committee membership change, and how does one become a member? Are steering committee meetings open to the public?
(2) GPS Accounts and Audits
How does TVA keep the books for GPS? What kind of a “fund” does TVA use to account for all GPS income and GPS outgo (expenses)? Since this “fund” receives voluntary contributions from the public (in exchange for certain promises), TVA must be legally and morally obliged to publish periodic income and expense reports, balance sheets, etc. Where are these reports?
Why doesn’t TVA ever publish any dollar figures about GPS (either on the production/expense side or on the sales/ income side)? How can the public know if TVA’s goals and vision are being realized (i.e. if TVA’s promises are being kept) if periodic financial reports are not published? (During Watergate, Deep Throat said “Follow the money.”)
Who audits the GPS accounts? Are the audits published? If not, why not? Why does TVA imply that CRS certifies the entire GPS program, when CRS (Green-e) concerns only production -- not expenses, sales, income and all other aspects of GPS?
CRS web pages speak of the Green-e Process Audit, the Green-e Marketing Compliance Review, and "pricing and contract disclosure to customers in the standardized format, required by the Green-e Code of Conduct." Where are these reports?
(3) GPS Production (and Cost of Production)
According to the KUB website, "TVA has indicated it would not make a decision on adding additional resources until existing Green Power generation is approaching full utilization." When does TVA foresee this happening? What "additional resources" does TVA intend to add? In other words, when should the public expect TVA to acquire truly significant green power productive capacity (or other sources of green energy)?
What is green, and what is not green? Why can’t TVA take credit for clean hydro, no-carbon nuclear power, and certain methane projects? Why can’t TVA count 358 MW of hydro modernization (HMOD) in FY99-06, 3 MW from Colbert wood waste cofiring, and 2 MW from Middle Point landfill gas as part of GPS? If so, GPS capacity would be more than ten times its present size.
Apparently the renewable portfolio standard (RPS) adopted by the House of Representatives on August 4 would count such existing renewables. If this becomes law, will TVA sell two different kinds of renewable energy – or combine the GPS and RPS definitions into one? Why did TVA oppose the Senate version of this bill last June?
What expenses does TVA charge to the GPS “fund” (e.g. R&D, land leases, debt service, marketing and advertising, travel by GPS executives)?
Since methane from wastewater is being used to produce GPS power in Memphis, why can’t the same technology be used at every other large city in the TVA region? What are the terms of TVA’s contract with the Memphis wastewater facility? Why does the latest "generation update" show no Memphis production at all in June-August 2007?
What happened to the Middle Point landfill methane project north of Murfreesboro which once was but is no longer part of GPS? Why hasn’t any other landfill methane project been made part of GPS?
Why does the TVA website publish detailed daily statistics for each of the 16 solar sites (a very tiny part of GPS) but only very generalized and sometimes missing quarterly statistics for the vastly more important wind and methane generation projects?
(4) Buffalo Mountain
Is Senator Lamar Alexander correct when he says that TVA expected a 35-38% capacity factor but obtained only 19-24% on Buffalo Mountain? If so, why did TVA invest (or cause Invenergy to invest) in additional wind turbines on Buffalo Mountain?
TVA’s deal with Invenergy is described as a 20-year, $60 million power purchasing agreement (PPA), but what are its exact terms? How do GPS subscribers benefit from this PPA? Who suffers the financial consequences of Buffalo Mountain's under performance? GPS or Invenergy? Why did Invenergy pay a penalty to TVA in 2006? What are the terms of TVA's (and Invenergy's?) lease(s) with the Coal Creek Mining Co.?
Why did TVA abandon the Regenesys plant which was originally linked to the Buffalo Mountain wind farm as part of GPS?
What are TVA's current conclusions about wind power sites on other Appalachian ridges, particularly in the light of Buffalo Mountain's disappointing performance?
(5) GPS Distribution and “Imports”
Why don't all 158 of TVA's distributors market GPS? What is the geographic distribution of the 105 (or so) distributors which do market GPS? What is the geographic and demographic distribution of GPS subscribers? How much power is lost during transmission between the sources of GPS (principally Buffalo Mountain and the Allen Fossil Plant) and individual GPS subscribers?
Since FERC Order 888 required utilities in 1996 to open their transmission lines to competitors, why can't TVA purchase low-cost green power from North Dakota (or wherever it’s available) and sell it in the Tennessee Valley? Can’t TVA purchase renewable energy certificates (REC’s or TRC's) from the open market and resell this electricity as part of GPS?
Can individual consumers in the Tennessee Valley purchase green power from low-cost sources outside the TVA region? Can they purchase any kind of power from outside the TVA region? Can they purchase and use REC's or TRC's from green power producers outside the TVA region?
(6) GPS Sales (and Income from Sales)
Why does TVA say or imply that GPS sales (voluntary contributions) are the true measure of “demand” for green energy? Isn’t this inconsistent with TVA's market research which reported that "84% of customers surveyed said they would like a green power product"? What are the pros and cons of GPS' becoming a "mandated program"?
Why does TVA insist that the amount of GPS sold is the measure of “demand” for green energy? Isn’t this inconsistent with TVA's market research which reported that "84% of customers surveyed said they would like a green power product"? Has TVA conducted any surveys about public attitudes toward GPS in the last seven years?
Does the GPS "fund" include as income the base rate TVA and its distributors charge for green power -- or just the GPS surcharge ($4.00/block = $4.00/150 kwh)?
Jerry Cargile is quoted by the Chattanooga Times Free Press (April 22, 2007) as saying that TVA generates about 31% more power from renewable sources that customers buy through GPS. What are the actual numbers? How have they changed over time? What are TVA's projections?
The latest TVA environmental report says the "target" for GPS sales is 39,700 blocks in 2007. A TVA spokesman said May 1 that monthly sales now surpass 30,000 blocks and that 8,457 residences and 453 businesses are buying almost 55 million kwh/year. The TVA spot currently being broadcast on WUOT says "more than 10,000 people are embracing the wind, the sun, and the earth..." How do you reconcile all these numbers -- and total kwh?
TVA claims that GPS has grown steadily over seven years, but this is net growth. How many consumers have stopped subscribing to GPS in each year? What reasons do consumers give when they withdraw from GPS?
What is the total number of residences served by electricity from TVA? What percentage subscribes to GPS, and what percentage is needed for the long-term viability of GPS? Is it true (as reported in the press) that only 422 blocks were sold in Nashville during July 2007? If so, this would be only 422/30,000 = 1.4% of all GPS blocks.
Stephen Smith (executive director of SACE) was quoted in the newsletter of the Tennessee Citizens for Wilderness Planning on Nov. 7, 2005, as saying that the key to increasing participation in Green Power may be to move from voluntary to mandated programs. How would a "mandated" green power program work? What is TVA's position on such a program? Shouldn't this be discussed with the public?
(7) GPS Marketing and Advertising
Since GPS is the only power "product" which TVA markets directly to the public, GPS must be an important component of TVA's total public relations. Does the large amount of money which TVA spends on GPS marketing and advertising unfairly divert public opinion away from other TVA issues like air quality, acid rain, smoke stack emissions, mountaintop removal, land deals, the production of tritium, and nuclear safety?
GPS seems to have insulated TVA from the criticism of environmental organizations. What in fact have the various environmental organizations said about GPS? What is TVA’s relationship to Stephen Smith (executive director of SACE) who seems to been a major supporter of GPS from the very beginning?
In December 2006, Jim West said that GPS "had already secured 'early adopters' [so] we tailored our media to reach more affluent and younger groups." How does TVA allocate GPS marketing and advertising resources both geographically and demographically? Is it true that TVA targets GPS advertising toward up-scale urban markets and away from down-scale rural markets?
What does the TVA spot on WUOT mean by “growing movement”? How can TVA justify the spot’s implication that GPS is similar to true social movements such as the civil rights movement?
Why do TVA and KUB continue to claim – despite analysis to the contrary -- that two blocks ($8 per month) is the environmental equivalent of planting an acre of trees in the Tennessee Valley?
Why does TVA’s literature on GPS make no reference to carbon dioxide reductions?
(8) TVA Strategic Plan
Why isn’t GPS (or even renewable energy in general) mentioned in TVA’s new strategic plan? Since it's not in the strategic plan, is there any other kind of long-range plan for GPS?
What has TVA learned from or about the TVA employee who criticized the strategic plan for not mentioning Green Power? According to the Knoxville News Sentinel, he wrote publicly in May 2007, "TVA needs to take a hard look from an ethical perspective in marketing this product [GPS]. It appears to be an Enron-type house build on sand with no apparent accountability to the customer." Why has this and the other criticisms of the draft strategic plan been taken off of the TVA website?
GPS has operated virtually unchanged for seven years. What does TVA envision for the future of GPS? Will GPS continue unchanged for a second seven years? What are the pros and cons of GPS' becoming a "mandated program"?
(9) Other TVA Policies
It’s been said that all of our future energy needs can be met through conservation, efficiency, and renewables (in that order). What is TVA doing in the areas of conservation and efficiency?
Representative Bud Cramer (co-chair of the TVA Caucus) said early this year that he "fears TVA is reverting to a bureaucracy that considers itself unaccountable to the public." Has TVA defended itself against this charge?
Does TVA plan to respond to (or even acknowledge) the letter about GPS transparency which was read to the TVA Board on August 1, 2007, by Eugene Burr of Tennessee Valley Unitarian Universalist Church (which buys 25 blocks/month)? (A copy is attached.)
Why does TVA claim “commercial confidentiality” with regard to GPS accounts? Presumably TVA's competitors are producers in bordering areas, but how exactly do they "compete" with TVA? How would the release of data about GPS production and consumption place TVA at a competitive disadvantage? Is TVA in a competitive or regulated market for electricity?
How does government ownership make public access to TVA information any different from the public’s right to obtain information from a publicly traded corporation?
What happened to the Public Power Institute (PPI) which TVA created in 1999 in part to develop renewable energy and which signed two memoranda of understanding with ORNL in 2000 "to work together in collaborative efforts to develop and deploy sustainable energy technologies"?
Questions respectfully submitted Sept. 19, 2007
By Edward W. Lollis, Knoxville, Tennessee
Phone: 865-690-8742
Email: geovisual at comcast.net
